Ceemet has chosen to not comment in detail on the transposition and implementation of the Directive at Member State level. Instead, Ceemets views concern issues that are related to the EU Directive and not to national transposition and are set out in the response to question five.

One of the fundamental problems that has been caused stems from a series of rulings from the European Court of Justice. They have created difficult implementation issues, some sectoral, some more general and have led to major problems for many companies and sectors in the organization of working time.

This legal uncertainty has primarily been caused by judgments from the Court of Justice and not the Directive itself. The impact of these decisions has been widely felt by employers and have generated considerable additional cost, both direct and administrative. In turn, this together with the uncertainty surrounding the requirements placed upon employers, has had a damaging effect on companies’ competitiveness and their ability to invest and grow.